https://www.taxtmi.com/caselaws?id=392781 Receipts for producing live cricket match coverage were not royalty because the payment was for creating and supplying the live feed, not for granting any right to use copyright or similar property. The distinction between a broadcast right and copyright was treated as material, and the receipts therefore fell outside the royalty definition. The same receipts were also not fee for technical services because the technical expertise used in production was not made available to the recipient for independent use; no know-how, skill or process was transferred enabling the recipient to produce the feed itself. The ad hoc profit attribution between the PE and head office was remanded for fresh adjudication. en-us Mon, 24 Feb 2020 00:00:00 +0530 Thu, 27 Feb 2020 08:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=392781 Receipts for producing live cricket match coverage were not royalty because the payment was for creating and supplying the live feed, not for granting any right to use copyright or similar property. The distinction between a broadcast right and copyright was treated as material, and the receipts therefore fell outside the royalty definition. The same receipts were also not fee for technical services because the technical expertise used in production was not made available to the recipient for independent use; no know-how, skill or process was transferred enabling the recipient to produce the feed itself. The ad hoc profit attribution between the PE and head office was remanded for fresh adjudication. Case-Laws Income Tax Mon, 24 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=392781